Migrant Worker Policy
Reviewed: March 2024

CONTENTS
OUR COMMITMENT

03

DEFINITIONS

03

SCOPE

04

COMPLIANCE

04

LEGAL REQUIREMENTS

05

REFERENCES

05

OVERALL PRINCIPLES

05

RESPONSIBLE RECRUITMENT PRINCIPLES

06

RESPONSIBLE RECRUITMENT

08

APPENDIX 1: ILO DEFINITION OF RECRUITMENT FEES AND COSTS: FOR
EMPLOYERS TO COVER

11

APPENDIX 2: MIGRANT WORKER EMPLOYMENT DOCUMENTS AND
CONTRACTS CHECKLIST11MIGRANT WORKER POLICY / 2024

2

OUR COMMITMENT
Burberry is committed to ensuring that all workers within its supply chain aretreated fairly and ensuring that labour rights are upheld.

Unfortunately, migrant workers can be vulnerable to unfair working
conditions, exploitation and forced labour.
This Burberry Migrant Worker Policy (the “Policy”) outlines how Burberry
expects its Business Associates, to treat migrant workers in their own
companies and throughout their supply chains.
Burberry encourages its suppliers to review the Guide to Implementing the
Dhaka Principles for specific step by step guidance to introducing bestpractice policies and processes. To enable this, we have referenced therelevant Dhaka Principle throughout the policy.
Burberry recognises that Business Associates may require support to comply
with this Policy. Burberry is committed to supporting all Business Associates
on their journey of improvement to ensure all migrant workers are treatedfairly and with dignity.
This Policy is based on:• The Ethical Trading Initiative (ETI) Base Code• The United Nations Universal Declaration of Human Rights• The Fundamental Conventions of the International Labour Organisation(ILO)• International Convention on the Protection of the Rights of All MigrantWorkers and Members of Their Families• The Dhaka Principles for Migration and Dignity
Burberry requires its Business Associates to respect the above principles andconventions and adhere to the provisions within this Policy.
DEFINITIONS“Business Associates” refers to any individual, entity, business, company,
partnership or any other body or group associated with Burberry including,
without limitation, any such individual, entity, business, company, partnershipor any other body or group supplying products, goods, raw materials,
components, services, real estate or anything else, directly or indirectly, to any
member of the Burberry Group or otherwise working directly or indirectly withor on behalf of any member of the Burberry Group. This also includes any
person (an “Indirect Supplier”) providing products, goods, raw materials,
components, services or anything else to (i) a direct supplier of Burberry or any
other member of the Burberry Group or (ii) any other Indirect Supplier.

Burberry Associates include, without limitation, the following:• finished goods vendors• raw material and/or component suppliers

MIGRANT WORKER POLICY / 2024

3

•
•
•
•
•
•
•
•
•
•
•
•
•

people or entities who carry out any processing on any goods directly or
indirectly supplied to Burberry, including sites at which this processing
takes place
non-stock vendors
construction contractors (and their construction sites)
franchisees
licensees
joint-venture partners
consultants
contractors
wholesale customers
service providers, including circular business model service platforms
agentslandlords, andany subcontractor of the above

All Business Associates must comply with the Responsible Business Principles
and such compliance is a condition of working with Burberry (whether directly
or indirectly).
“Migrant workers”: A person who is engaged or has been engaged in a
remunerated activity in a state of which he/she is not a national.
“Recruitment agents”: Migrant recruiters, also known as labour brokers or
recruitment agencies, are intermediaries that supply migrant workers for theuse of other business enterprises, usually on the basis of agreements withthese business enterprises as well as agreements with the migrant workers
concerned. They perform various functions, which can include matchingmigrant workers to jobs in other parts of the country or abroad, arranging forvisas, making travel arrangements, and providing pre-departure orientation ortraining. The term ‘labour brokers’ is sometimes used to apply to organisations
that, in addition to recruiting migrant workers, also manage them at the jobsite. Migrant recruiters should be legally recognised and duly authorised to
conduct all of the functions they perform. However, there are migrant
recruiters that are not legally recognised business enterprises and that do notnecessarily carry out activities in accordance with applicable law.
SCOPE
The Policy covers all our Business Associates.
COMPLIANCE
To ensure all workers are treated fairly and labour rights are upheld, allBusiness Associates are required to demonstrate full adherence to this Policy
prior to onboarding with Burberry. New Business Associates should conduct
due-diligence of their labour practices to ensure that they are fully incompliance with the Policy. Evidence of the compliance of the Policy, e.g.
reimbursement of recruitment fees to migrant workers and use of legal
recruitment agents, may be requested for review at any time.

MIGRANT WORKER POLICY / 2024

4

LEGAL REQUIREMENTS
Business Associates should ensure that they adhere to the applicable nationallaw in both the host country and (if applicable) the country of origin of
migrant workers, and any other applicable laws. Where the provisions of thelaw and this Policy address the same subject, Business Associates should
apply the provision that gives migrant workers the greater benefit .
REFERENCES• The Ethical Trading Initiative (ETI) Base Code• The United Nations Universal Declaration of Human Rights• The Fundamental Conventions of the International Labour Organisation(ILO)• International Convention on the Protection of the Rights of All MigrantWorkers and Members of Their Families

Burberry requires its Business Associates to respect the above principles andconventions and adhere to the provisions within this Policy.
OVERALL PRINCIPLES
1. Equality
Dhaka Principles – Core Principle A – All workers are treated equally andwithout discrimination.

1.1 Each worker should have the same rights and terms and conditions of
employment as national or local workers employed by the Business Associate,including (but not limited to) being eligible for the payment of a national
minimum wage (unless otherwise stipulated by law, such as in relation tosocial security benefits).
1.2 All workers should be treated equally and without discrimination.
1.3 Migrant workers should be treated no less favourably than other workers
performing the same or similar work.
1.4 Moreover, migrant workers should be protected from any discriminationthat would constitute a violation of human rights.
1.5 Employers should not discriminate against migrant workers on the basis of
ethnicity, gender, national or social origin, caste, age, politics, religion, sexual
orientation, union membership, disability, health (e.g. HIV), pregnancy, or any
other status, in line with local and national labour law, or international humanrights standards where these provide more protection for the worker.
1.6 Migrant workers should have appropriate access to training, promotional
opportunities, working hours, pay, overtime, benefits, healthcare, union rights,
and collective bargaining agreements without discrimination. Disciplinary
procedures and termination policies should be fair, transparent and based onan equal treatment principle.

MIGRANT WORKER POLICY / 20245

1.7 Medical or pregnancy testing should not be used as a means of screening
applicants for employment, and should only be conducted where required by
the law. The results should only be used for legally required purposes, or to
make suitable provisions, e.g. in accommodation or healthcare provision.
2. Legal Protection
Dhaka Principles: Core Principle B – All workers enjoy the protection of
employment law

2.1 All workers enjoy the protection of employment law. Migrant workers
should have a legally recognised employment relationship with an identifiable
and legitimate employer in the country where the work is performed.
3. Age3.1 Migrant workers under the age of 18 should not be recruited.

3.2 It is the employer’s responsibility to conduct due diligence to avoid
recruitment of migrants under the age of 18 years.
3.3 Business Associates and their recruitment agents must have procedures inplace to verify each migrant worker’s age as a part of the recruitment
process.
3.4 Business Associates and their recruitment agents should have a remedial
procedure in place to manage any cases where a migrant worker under theage of 18 was recruited. For more information, please see Burberry’s Child
Labour and Young Worker Policy.
RESPONSIBLE RECRUITMENT PRINCIPLES
1. Recruitment Agents
1.1 Where possible, the Business Associate should avoid using recruitment
agencies, and instead recruit workers directly. If using a third party, theBusiness Associate should work with a government registered recruitment
agency where possible.

1.2 Business Associates are recommended to develop their own referralmechanisms for new recruitment, whereby existing workers can referfriends or family for recruitment opportunities, where possible. Anyreferral mechanism should include clear guidance to existing workers. A
referral mechanism could assist in eliminating the use of brokers, where it
is common practice for recruitment fees to be issued and there is a lack oftransparency in the information provided to workers. This will contributeto significant risk reduction for new workers, especially regarding fees
being paid in their country of origin.
1.3 The Business Associate should have clear contracts with any recruitment
agency they use, and ensure that the recruitment agency is required to, anddoes, adhere to Burberry’s Ethical Trading Code of Conduct and this Policy.
The Business Associate will pay the recruitment agency all legally allowed

MIGRANT WORKER POLICY / 2024

6

fees. The Business Associate should also keep copies of contracts between
each party (e.g. agent and sub-agent(s)).
1.4 The recruitment agency should provide the Business Associate full detailsof the use of any sub-contractors or sub-agents used to hire workers.
2. FeesDhaka Principles: Principle 1 – No fees are charged to migrant workers

2.1 The employer should bear the full costs of recruitment and placement.
2.2 Migrant workers should not be charged any fees for recruitment orplacement (whether outright or through wage deductions).
2.3 If any worker already employed by the Business Associate has previously
paid for any Recruitment Fees, the Business Associate shall reimburse such
worker for any fees paid by the worker. Recruitment Fees means the fees tobe covered by the employer in accordance with the ILO, as detailed inAppendix 1).
2.4 The Business Associate should not retain any Recruitment Fees from theworker’s wage. Furthermore, the Business Associate should not retain any
money from the worker or deduct money from the worker’s wages including
but not restricted to levies, deposits or guarantee monies (sometimes known
as runaway insurance), or compulsory savings schemes.
2.5 The Business Associate is responsible for any Recruitment Fees incurredfor employment upon either verbal or written confirmation of theemployment.
2.6 The Business Associate (including all employees and representatives orany person affiliated with the Business Associate) should not accept any
reimbursement or bribe from any recruitment agency or other person ororganisation involved in the recruitment of any worker.
3. Right to Work
3.1 Business Associates must ensure that migrant workers have all
documentation required by law to work in the country of work.

3.2 In the event that migrants are employed who do not have adequate
evidence of the legally required documentation, the Business Associate should
support the worker, and cover the cost of obtaining the required legal
documentation and right to work.
3.3 In the event that a worker is unable to obtain legal right to work, theBusiness Associate is responsible for the cost of humane repatriation if theworker chooses to return to their home country.
4. Employment Documents and Contracts
Dhaka Principles: Principle 2 – All migrant worker contracts are clear andtransparent

MIGRANT WORKER POLICY / 2024

7

4.1 Migrant workers should be provided with written contracts in a language
each worker understands, with all terms and conditions explained clearly, andthe worker’s assent obtained without coercion. Where the worker is illiterate,
the contract and terms of employment should be fully explained to theworker.
4.2 Contracts should include the criteria included in Appendix 2 of this Policy:
Migrant Worker Employment Documents and Contracts Checklist.
4.3 Contracts should be signed, prior to deployment (migration), and adequate
time should be allowed so the full implications of the contract can beunderstood prior to signature. Contracts should be signed at least 7 days prior
to departure. Contract signing at the border entry or point of arrival, or any
time thereafter should be prohibited.
4.4 On arrival, contracts and terms and conditions should be checked forconsistency with the contract agreed at the time of recruitment by a workers’
representative.
5. Orientation
5.1 Migrant workers should receive adequate orientation relating to living andworking in their host location. Migrant workers should receive the employer
handbook and/or work regulations in a language they understand.

5.2 The orientation programme should include: basic job training, health andsafety information, production requirements, legal rights and responsibilities,
workplace policies, rules, disciplinary systems, and communications systems,
grievance channels and processes, living conditions and, if applicable,
dormitory rules, basic local language skills, culture and common practices,
advice about safe sex, reproductive health, HIV/AIDS prevention, andawareness of and prevention skills related to most relevant diseases.
For more information, please see BSR Migrant Worker Management Toolkit
RESPONSIBLE RECRUITMENT
1. Integration
1.1 Business Associates should encourage 2-way communication with theirmigrant workforce in making integration comfortable, mutually beneficial andsustainable.

1.2 The Business Associate should assign a worker that is able to speak andunderstand both the migrant worker’s language and the managements
language to coordinate communication. Where there is no worker with suchskills, the Business Associate should employ an onsite worker coordinator
who is able to speak and understand the languages of the migrant workers
and management languages. This worker coordinator should not be involvedin the recruitment process; these roles should be clearly separated.

MIGRANT WORKER POLICY / 20248

1.3 Communication should be facilitated between the workers and theirfamilies by providing low cost systems. Free provision of computer and
WIFI access should be considered. Where grievance systems are reliant on
smart technology, access to WIFI must be provided. This can be limited tobreak-times and communal locations.
2. Policies
Dhaka Principles: Principle 3 – Policies and procedures are inclusive.

2.1 Migrant workers’ rights should be explicitly referred to in employer andmigrant recruiter public human rights policy statements, relevant operational
policies and procedures addressing human rights responsibilities.
2.2 Business Associates should communicate to all workers a policy statingthat the employer will bear the full costs of recruitment and placement(including all Recruitment Fees as specified in Appendix 1), and no fees should
be applied to the workers, including those hired locally.
3. Document Retention
Dhaka Principles: Principle 4 – No workers’ passports or identity documents
are retained

3.1 Migrant workers should have free and complete access to their own
passport, visa, identity documents, ATM or credit cards, banking book andresidency papers, and enjoy freedom of movement.
3.2 Migrant workers should have access to individual, safe, lockable storagefor important documents and other valuables.
4. Remuneration
Dhaka Principles: Principle 5 – Wages are paid regularly, directly and on time

4.1 Migrant workers should be paid what they are due on time, regularly anddirectly.
4.2 Final wages and any redundancy or equivalent payment, if applicable,
should be paid in full at the end of the contract before the worker leaves.
4.3 Migrant workers should be granted paid leave by the Business Associate
when workers need to take time off to process recruitment related
documents, such as passport renewals and visa extensions.
5. Worker Representation
Dhaka Principles: Principle 6 – The right to worker representation are be
respected

5.1 Migrant workers should have the same rights to join and form trade unions
and to bargain collectively, as should other workers.
6. Working Conditions
Dhaka Principles: Principle 7 – Working conditions are safe and decent.

MIGRANT WORKER POLICY / 2024

9

6.1 Migrant workers should enjoy safe and decent conditions of work, freefrom harassment, any form of intimidation or inhuman treatment.
6.2 They should receive adequate health and safety provision and training in
relevant languages.
7. Living Conditions
Dhaka Principles: Principle 8 – Living conditions must be safe and decent.

7.1 Migrant workers should be able to choose whether to live in companyprovided housing or to make their own living arrangements.
7.2 Living or overnight accommodation should be separate from any
manufacturing facilities or any production floors and should be safe and fit for
purpose.
7.3 Migrant workers should enjoy safe and hygienic living conditions, and safe
transport between the workplace and their accommodation.
7.4 All accommodation provided by the employer to migrant workers should
be safe, clean and hygienic, with potable and running water, adequate sanitaryfacilities, as well as temperature-control equipment where necessary.
Buildings should meet all laws concerning multiple occupancy dwelling andlocal building regulations.
7.5 Migrant workers should not be denied freedom of movement, or confinedto their living quarters.
8. Access to Remedy
Dhaka Principles: Principle 9 – Access to remedy is provided

8.1 Migrant workers should have access to judicial remedy and to credible
grievance mechanisms, without fear of recrimination or dismissal.
8.2 All workers should have access to judicial or non-judicial grievancemechanisms beyond the company level, including legal complaints procedures.
Migrant workers should not be denied access to consular services.
8.3 Business Associates should provide access to, and widely communicate,workplace level grievance mechanisms, such as worker hotlines.
9. Freedom to Change Employment
Dhaka Principles: Principle 10 – Freedom to change employment is respected,
and safe, timely return is guaranteed.

9.1 Freedom to change employment is respected, and safe, and timely return isguaranteed. Migrant workers should be guaranteed provision for return homeon contract completion and in exceptional situations. They should not,however, be prevented from seeking or changing employment in the hostcountry on completion of first contract or after two years, whichever is less.

MIGRANT WORKER POLICY / 2024

10

9.2 Where migrant workers terminate their contract early, there must be no
penalty for doing so except where established in the worker’s originalcontract, and the worker must be given access to all savings and receive theusual assistance in repatriation.
APPENDIX 1: ILO DEFINITION OF RECRUITMENT FEES AND COSTS: FOR
EMPLOYERS TO COVER

RECRUITMENT FEES

Covers recruitment, referral and placement services that can involve advertising,disseminating information, arranging interviews, submitting documents for government
clearance, confirming credentials, organising travel and placement into employment.

MEDICALCOSTS

INSURANCECOSTSSKILLS &QUALIFICATIONSTRAINING &ORIENTATIONEQUIPMENTCOSTS

TRAVEL &LODGINGADMINISTRATIONCOSTS

MedicalExaminations

Mandatory
government
insurance

Language
profiency tests

Mandatory
training

Tools

Application andservice fees

Skills andqualification tests

Pre-departureand post-arrival
training

Including fortraining,
interviews,
consularappointments

Tests
Vaccinations

Health andsafety ofworkers
Enrolment inmigrant
welfarefunds

Certification or
licensingOn-site training

Uniforms
Safety gear

Relocation
Return or
repatriation

Employment
contracts,
passports*, IDs,
visas, backgroundchecks, security &exit clearance,banking services,
work & residence
permit*Passport fees should be covered by the Business Associate for: (a) workers whose first passport is for the job offeredby the Business Associate; or (b) workers whose passport requires renewal for employment under the Business
Associate.

APPENDIX 2: MIGRANT WORKER EMPLOYMENT DOCUMENTS AND
CONTRACTS CHECKLIST

Employment Documents (including, but not limited to, contracts and otherorientation materials) should include:• The worker’s name, date of birth, birthplace, nationality, and otherunique identity information, e.g. passport number, place and date ofissue, and expiry.
• The worker’s emergency contact details.
• A basic job description• Identification of the site of employment.
• The duration of the contract and renewal conditions. The renewal
conditions should make it clear that the employer will bear the fullcosts of extending working visas and other costs associated with
contract extension.
• A comprehensive breakdown of all legitimate recruitment expenses(e.g. travel, medical checks and travel documents) to be covered by the

MIGRANT WORKER POLICY / 2024

11

•

•
•
•
•
•

•
•

•
•
•
•

employer. The contract should make it clear that no recruitment orplacement fees will be charged to the worker.
Regular hours of work, expected overtime, frequency of rest days, andholidays. It should spell out the maximum amount of overtime hours
permitted consistent with national law or the prevailing industry
practice whichever is the least onerous.
Basic, overtime, and holiday rates of remuneration, and an estimate of
the worker’s minimum monthly net pay.
A clear explanation of the terms of payment of the salary to theworker, including method and frequency of payment.
A list of all bonuses and allowances where they exist, as well as any
non-cash compensation and work-related benefits, such as medical andsocial security benefits and sick, emergency, and annual leave.
Outline of sickness and employment injury compensation, andemergency medical care procedures.
A clear description of all the conditions and the level at which theemployer may make deductions from remuneration. Agreed
deductions, such as for accommodation, food, medical care, should bereasonable.
No provisions that would prohibit or have the effect of discouraging
workers from exercising their right to form or join trade unions and to
bargain collectively subject to applicable laws and regulations.
Describe the working and living conditions, including any costs foraccommodation, food and transport, any curfews and/or any
restrictions on freedom of movement arising from local laws orlegitimate security concerns.
A reasonable notice period stipulated for the termination of theemployment contract by the employer and the worker.
Any reasons for which a contract may be prematurely terminated.
Outline of complaints and grievance mechanisms systems, and asettling of dispute clause.
Clauses guaranteeing safe and timely return home at the end ofcontract, or during the contract in emergency situations, or in the caseof the employer terminating the contract.

MIGRANT WORKER POLICY / 202412